Keep it Simple: How to Craft a 121 SMS Program

Richard Komarniski is a believer in keeping things as simple as possible when it comes to regulations. What the president of Canadian-based Grey Owl Aviation Consultants found when he talked to Canadian carriers charged with implementing a safety management system (SMS) was that some of them “made it too complicated.” So complicated “that even the president of the company … didn’t understand the program.”

Where SMS per se comes into play, he contends, is “the safety of the aircraft and safety of the operation itself.” Komarniski believes a lot of people think they must factor employee safety into the same equation for SMS purposes. Worker safety, of course, is absolutely critical. But the Grey Owl chief asserts too many carriers and maintainers are trying to blend operations safety and OSHA-like safety concerns, thus becoming “quickly overwhelmed” by the task.

So overwhelmed that four years ago, when all Canadian carriers were audited “not too many” passed. That, contends Komarniski is because a majority of them tried to lump employee safety in with SMS. They found themselves in over their heads because they had neither the resources nor controls in place to meld the two. As a result he says, “employees did not understand what SMS was.”

If neither the person who’s supposed to be running the show nor the guy on the shop floor get it, it’s a safe bet a safety audit will reflect confusion.


Communication is critical

Komarniski is quick to point out some companies do get it. They fashion SMS that mesh operational safety and employee safety in a way that makes sense. They communicate among operational units so that everyone is on the same page, literally and figuratively. This is especially true when it comes to manuals.

While FAA Part 121 SMS rules governing air carriers are (as of this writing) still in draft form and, and Part 145 regulations are still down the line, many U.S. airlines and major repair organizations alike are already immersed in preparation.

MRO AAR isn’t trying to create the wheel anew. “Making it a big, complex new program is probably a mistake,” says Rayner Hutchinson, AAR’s vice president of quality and safety. “We’ve worked hard to try to integrate SMS concepts into our regular procedures manual.”

Not only does AAR bring operational safety under one roof, the MRO “has gone to great lengths to try to integrate [workplace safety].” He says if an auditor is on the hangar floor to ensure AAR follows regulations regarding maintaining a customer’s aircraft, why not audit for worker safety at the same time. “It is not,” says Hutchinson, “rocket science.”

He says the results have been “pretty good,” in a number of instances opening up new avenues for corrective action. “When people on the floor are faced with things that don’t work … [those manuals] have been another advertisement for ‘Here’s how you get this corrected.’”

Armando Martinez understands. Miami Air International’s senior director of safety and security is a true believer in keeping it simple, in ensuring clear, unambiguous communication among units. The south Florida-based charter company operates a fleet of five Boeing 737-800s and two 737-400s.

Before it started down the SMS road, Martinez says the carrier had separate technical publications departments for maintenance and operations. “There was no interfacing between the departments.” The gap had to be closed. He says a key query in FAA Safety Assurance Inspections is whether manuals and systems interfaced, whether communication-killing departmental silos have been toppled.

“Most people,” asserts Martinez, “don’t have that ability.”

Since implementing SMS, Miami Air has combined maintenance and operations pubs under one roof. This renders it easier to get the word out to all that need to know.

Take an AD dealing with installation of a cockpit warning light to signal pressurization problems. The “parent” manual is the QRH, the pilot’s Quick Reference Handbook. But Martinez says there are half a dozen other manuals where the installation needs to be noted. “It has to interface,” he reiterates. “When you’re making a change you need to consider what other departments might be affected.”


Coordinate across operating departments

This country’s largest domestic airline has a full-blown SMS program up and running, one that places a premium on “coordinating across the operating departments,” says Tim Logan, Southwest Airlines senior director of safety risk management .

Over the past five years he’s seen significant changes in that coordination. It’s “immensely different,” he says. Echoing Martinez, Logan says, “[Once] we might get an [internal] organization that would change something and not realize that it would affect two or three other organizations – until right before we implement[ed].” Now, the manual changes are right up front. “We try to do that as early in the process as we can.”

As with Miami Air, that means publications consolidate and cross-check to ensure “we don’t have one manual saying one thing and another manual another.”

Operating groups get together and review manual changes to make sure an “’Oh, wait a minute. You can’t do that’” moment doesn’t arise, and throw a monkey wrench into someone else’s operation.

Both Martinez and Logan say a good, adaptable content management system (CMS) is the critical element here, that and a bonafide corporate safety culture.

But Logan doesn’t want you to mistake communication for commonalty at all costs. He accedes each department has its own well-established means of meeting its regulatory and compliance responsibilities. “There’s a big difference between what the maintenance department does with a Continuing Analysis and Surveillance System (CASS) reliability type program and what flight operations does with [the] Aviation Safety Action Program (ASAP).”


Don’t toss out what works

There’s a fundamental fear folks have when putting together an effective, compliant SMS: they don’t want to toss out what works for their shop. Logan says, “You don’t want to remove things that are effective. My concern is that I’ve seen carriers try to change what the company is doing to match SMS.” He asserts instead that what’s needed is “to adapt what we’re doing, without changing it too much, [and] build an SMS process around it.”

Not changing things too much is much on the mind of AAR’s Hutchinson. By regulation, an MRO must follow a customer airline’s maintenance program. As a maintenance provider to multiple carriers, AAR is concerned as to whether it will “have multiple SMS imposed” on it, or if it can establish its own program that satisfy requirements. “We’re hoping the regulation will provide some relief,” Hutchinson says. The potential is present for an awful lot of confusion.

The potential is also there for profit. Grey Owl’s Richard Komarniski relates the case of a Canadian engine shop that implemented SMS. The president of the company did more than pay lip service to the process. He committed himself to the culture of safety, roaming the shop floor, asking employees ‘How can we do this better? How can we reduce warranty claims? What can we do to reduce test cell turnbacks?’

He listened, rolled up his sleeves, and helped employees fill out reports. Then took those reports to the company’s safety committee.

The result? Kormarniski says the executive believes implementing a safety management system was “the best thing I’ve ever done … I’m saving money in shops I never though I’d save money in. I’ve got engaged employees.” He called SMS payoff, “amazing.”

Simply amazing.